Capitol Comments
January 2014
When there is a deadline associated with an item, you will see this graphic:
Recent News
Agencies approve rule regarding TruPS CDOs
On January 14, 2014, the FDIC, OCC, SEC, and CFTC (U.S. Commodities Trading
Commission) (the agencies) approved an interim final rule1 to permit banking entities to
retain interests in certain collateralized debt obligations backed primarily by trust
preferred securities (TruPS CDOs) from the investment prohibitions of section 619 of
the Dodd-Frank Act, known as the Volcker rule.
Under the interim final rule, the agencies permit the retention of an interest in or
sponsorship of covered funds by banking entities if the following qualifications are met:
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the TruPS CDO was established, and the interest was issued, before May 19,
2010;
the banking entity reasonably believes that the offering proceeds received by the
TruPS CDO were invested primarily in Qualifying TruPS Collateral; and
the banking entity’s interest in the TruPS CDO was acquired on or before
December 10, 2013, the date the agencies issued final rules implementing section
619 of the Dodd-Frank Act.
The federal banking agencies on January 14th also released a non-exclusive list of issuers
that meet the requirements of the interim final rule.
The interim final rule defines Qualifying TruPS Collateral as any trust preferred security
or subordinated debt instrument that was:
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issued prior to May 19, 2010, by a depository institution holding company that as
of the end of any reporting period within 12 months immediately preceding the
issuance of such trust preferred security or subordinated debt instrument had
total consolidated assets of less than $15 billion; or
issued prior to May 19, 2010, by a mutual holding company.
Section 171 of the Dodd-Frank Act provides for the grandfathering of trust preferred
securities issued before May 19, 2010, by certain depository institution holding
companies with total assets of less than $15 billion as of December 31, 2009, and by
mutual holding companies established as of May 19, 2010. The TruPS CDO structure
was the vehicle that gave effect to the use of trust preferred securities as a regulatory
capital instrument prior to May 19, 2010, and was part of the status quo that Congress
preserved with the grandfathering provision of section 171.
The interim final rule also provides clarification that the relief relating to these TruPS
CDOs extends to activities of the banking entity as a sponsor or trustee for these
securitizations and that banking entities may continue to act as market makers in TruPS
CDOs.
The agencies will accept comment on the interim final rule for 30 days following
publication of the interim final rule in the Federal Register.
Comment: This interim final rule will mitigate the effects of the Volcker rule on the
capital of many community banks.
CFPB seeks new members for Advisory Boards and Councils
CFPB invited the public to apply for membership for appointment to its Consumer
Advisory Board (the “Board”), Community Bank Advisory Council, and Credit Union
Advisory Council. Membership of the Board and Advisory Councils includes
representatives of consumers, communities, the financial services industry and
academics. Appointments to the Advisory Board are typically for three years and
appointments to the Advisory Councils are typically for two years. The Bureau expects to
announce the selection of new members in August 2014. Click here2 to see the
background, qualifications, and application procedures.
Comment: In the fall, the following will become vacant: 7 seats on the Consumer Advisory
Board, 8 seats on the Community Bank Advisory Council, and 8 seats on the Credit Union
Advisory Council. The CFPB is looking for experts in a variety of disciplines (consumer
protection, community development, consumer finance, fair lending, civil rights, and
financial products and services), bank representatives in underserved communities,
representatives of communities significantly impacted by higher priced mortgages,
current community bank and credit union employees, and academics. Applications must
be received on or before February 28, 2014.
CFPB revises consumer mortgage publications including 2 required booklets
The CFPB announced the availability of three revised consumer publications, including
a consumer information brochure and two booklets required under the RESPA,
Regulation X, the TILA, and Regulation Z. Revision of Consumer Information The
publications are: What You Should Know About Home Equity Lines of
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Credit, the Consumer Handbook on Adjustable-Rate Mortgages (CHARM
Booklet), and the Shopping for Your Home Loan: Settlement Cost Booklet.
Comment: Send these to your mortgage lenders and tell them to bookmark them.
Unfortunately, the results of a search of the CFPB’s web site did not bring the revised
publications to the top of the list.
Annual adjustment to CRA asset-size thresholds
The federal banking regulatory agencies announced the annual adjustment to the assetsize thresholds3 used to define small bank, small savings association, intermediate small
bank, and intermediate small savings association under the CRA regulations. As a result
of the 1.39 percent increase in the CPI index for the period ending in November 2013,
the definitions of small and intermediate small institutions for CRA examinations will
change as follows:
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"Small bank" or "small savings association" means an institution that, as of
December 31 of either of the prior two calendar years, had assets of less than $
1.202 billion.
"Intermediate small bank" or "intermediate small savings association" means a
small institution with assets of at least $ 300 million as of December 31 of both of
the prior two calendar years, and less than $ 1.202 billion as of December 31 of
either of the prior two calendar years.
These asset-size threshold adjustments were effective January 1, 2014.
Comment: Current and historical asset-size thresholds are on the FFIEC website4.
Has CFPB effectively prohibited dealer markup in indirect auto lending?
The CFPB and the Department of Justice ordered5 Ally Financial and Ally Bank to pay
$80 million to harmed African-American, Hispanic, and Asian and Pacific Islander
borrowers and $18 million in penalties.
Comment: The CFPB may have effectively prohibited dealer markup in indirect auto
lending. If your bank buys dealer paper, you need to be aware of this. If you buy dealer
paper, you will either need to carefully monitor the fair lending risk of dealer markups or
eliminate dealer markup in favor of another dealer compensation structure. I think most
banks adopt the latter, less risky alternative. In March, the CFPB issued a bulletin
explaining that they would hold indirect auto lenders accountable for unlawful
discriminatory pricing. This order is their message that they mean business. It is odd
though that it comes against a bank whose majority owner is the U.S. government.
FinCEN requests BSA Advisory Group membership nominations
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FinCEN invites the public to nominate6 financial institutions and trade groups for
membership on the Bank Secrecy Act Advisory Group. New members will be selected for
three-year membership terms.
Comment: BSAAG membership is open to financial institutions and trade groups.
New members will be selected to serve a three-year term and must designate one
individual to represent that member at plenary meetings who must not be registered as a
lobbyist. Organizations must nominate themselves.
OCC Bulletin highlights guidance on deposit advance products
The OCC released OCC Bulletin 2013-407 highlighting the final guidance (“Guidance on
Supervisory Concerns and Expectations Regarding Deposit Advance Products8”
(guidance)) it and the FDIC finalized in November 2013. The guidance addresses safe
and sound banking practices and consumer protection in connection with deposit
advance products (DAP).
The guidance;
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outlines appropriate underwriting policies and practices, including establishing
customers’ eligibility and assessing their ability to repay while allowing borrowers
to continue to meet typical recurring and other necessary expenses.
requires banks to monitor DAP portfolios in accordance with established credit
risk standards such as capital adequacy, reliance on fee income, adequacy of the
allowance for loan and lease losses, etc.
implements a “cooling off” period of at least one monthly statement cycle after
repayment.
states that the OCC will take appropriate supervisory action to address unsafe
and unsound banking practices and any violation of consumer protection
statutes.
Comment: The Fed issued a Statement On Deposit Advance Products 9 last year that was
not nearly as detailed and the CFPB issued a white paper10 with initial data findings.
CFPB increases HMDA threshold to $43 million
The CFPB published a final rule11 amending the official commentary that interprets the
requirements of HMDA to reflect a change in the asset-size exemption threshold for
banks, savings associations, and credit unions based on the annual percentage change in
the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). The
exemption threshold is adjusted to increase to $43 million from $42 million. The
adjustment is based on the 1.4 percent increase in the average of the CPI-W for the 12month period ending in November 2013. Therefore, banks, savings associations, and
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credit unions with assets of $43 million or less as of December 31, 2013, are exempt
from collecting data in 2014.
Comment: The rule became effective January 1, 2014 and applies to data collection in
2014.
HPML escrow exemption threshold adjusted to $2.028 billion
CFPB amended12 the official commentary that interprets the requirements of Reg. Z to
reflect a change in the asset size threshold for certain creditors to qualify for an
exemption to the requirement to establish an escrow account for a higher-priced
mortgage loan based on the annual percentage change in the average of the Consumer
Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for the 12-month
period ending in November. The exemption threshold is adjusted to increase to $2.028
billion from $2 billion. The adjustment is based on the 1.4 percent increase in the
average of the CPI-W for the 12-month period ending in November 2013. Therefore,
creditors with assets of $2.028 billion or less as of December 31, 2013, are exempt, if
other requirements of Regulation Z also are met, from establishing escrow accounts for
higher-priced mortgage loans in 2014.
Comment: The rule became effective January 1, 2014, and applies to whether a creditor is
eligible for the exemption in 2014.
FDIC releases videos for bank directors, officers, employees
The FDIC released four new videos13 in its third installment of technical assistance
videos to provide useful information to bank directors, officers, and employees on
regulatory issues and proposed regulatory changes. These videos pertain to municipal
securities, the allowance for loan and lease losses, troubled debt restructuring, and fair
lending. The topics of the latest four videos are:
 Evaluation of municipal securities14
 Allowance for loan losses15
 Troubled debt restructuring16
 Managing fair lending risk17
Comment: This is the third installment of videos. The first installment of six videos was
released in April. The second installment of six videos was released in June. All of the
videos can be found here18. Some of these videos appear to be exclusively on the FDIC’s
YouTube channel—others can be watched on the FDIC’s website. Some banks block
YouTube, you will not be able to watch these on your desktop computer at work.
CFPB requests information on “pain points” of mortgage closing
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The CFPB published a notice19 in the Federal Register requesting information from the
public about mortgage closing. Specifically, the notice seeks information on key
consumer “pain points” associated with mortgage closing and how those pain points
might be addressed by market innovations and technology.
The CFPB is seeking to encourage the development of a more streamlined, efficient, and
educational closing process as the mortgage industry increases its usage of technology,
electronic signatures, and paperless processes. According to the CFPB, the next phase of
its Know Before You Owe initiative aims to identify ways to improve the mortgage
closing process for consumers.
The notice uses 17 questions to get this information from market participants,
consumers, and other stakeholders who work closely with consumers.
Comment: While it will be interesting to see the results of this information gathering by
the CFPB, it goes without saying that close to 100% of the pain points in closing a
mortgage loan are government creations.
CFPB updates mortgage origination and servicing exam procedures
The CFPB updated its mortgage origination exam procedures and mortgage servicing
exam procedures. The Supervision and Examination Manual20 provides guidance on
how the CFPB conducts examinations. These updates harmonize existing procedures for
handling mortgage origination and mortgage servicing examinations with the revised
interagency procedures that address the new mortgage regulations issued in January
2013, which have now taken effect. The exam procedures for both mortgage origination
and mortgage servicing now cover final rules issued by CFPB through November 2013.
These examination procedures will be incorporated into the Supervision and
Examination Manual at a later date.
Comment: Forward to internal audit.
Call Report for Fourth Quarter 2013
The materials21 attached to FIL-1-201422 pertain to the Call Report for the December 31,
2013, report date. Please plan to complete the preparation, editing, and review of your
institution’s Call Report data and the submission of these data to the agencies’ Central
Data Repository (CDR) as early as possible. Starting your preparation early will help you
identify and resolve any edit exceptions before the submission deadline. If you later find
that certain information needs to be revised, please make the appropriate changes to
your Call Report data and promptly submit the revised data file to the CDR.
Except for certain institutions with foreign offices, your completed Call Report must be
received by Thursday, January 30, 2014, in accordance with the filing requirements
discussed below. No extensions of time for submitting Call Report data are granted.
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CFPB launches nationwide education campaign about new mortgage rules
The CFPB launched a campaign to educate the public about the new protections
provided by the CFPB’s mortgage rules. The CFPB released educational materials,
including:

Sample Letters: The Bureau released sample letters that consumers can use to
find solutions to various problems with their mortgage servicers. The sample
letters address such topics as:
o
Requesting that a servicer correct errors23: Consumers should use this
letter template if they think their servicer has made an error. The
instructions for the template describe what information to include in a
letter to a servicer, how to identify the error, and include other tips. The
template also tells consumers what to expect from the servicer and
provides a general idea of the timeline of events once the letter is sent.
o
Requesting information from a servicer24: Consumers should use this
letter template if they need information from their mortgage servicer. The
instructions for the template describe what information to include in a
letter to a servicer, examples of information requests, and include other
tips. The template also tells consumers what to expect from the servicer
and provides a general idea of the timeline of events once the letter is sent.

Guide for Housing Counselors: This guide25 is designed to be a quick
reference for housing counselors. The CFPB will also be offering training on the
rules for housing counselors.
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Mortgage Tips: The CFPB is providing a number of different tips on new rights
under the new rules for homebuyers26 and homeowners27 at every stage of the
mortgage process— from taking out a loan to paying it back. The tips also include
recommendations28 for troubled borrowers facing foreclosure.
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Answers to Consumer Questions: The CFPB published mortgage-related
questions29 to AskCFPB, an interactive online tool designed to answer
consumers’ most frequently asked questions in plain language.
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Consumer Tools: The CFPB website offers a tool30 to help consumers find local
housing counseling agencies. Consumers that have an issue with consumer
financial products or services, such as a mortgage, can also submit a complaint31.

Factsheets on the Rules: The CFPB published a factsheet32 with an overview
of all of the new consumer protections in the CFPB’s mortgage rules. The CFPB
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also published a summary33 of the new procedures to facilitate borrowers’ access
to foreclosure avoidance options.
Comment: The CFPB has a lot of information on its website for consumers. This campaign
highlights much of that information. Your bank might use some of these resources to
educate applicants about the new mortgage rules. There is a real fatigue among
consumers at hearing that “it is a government requirement.” These resources may help
the consumers understand the new rules and understand that when the banker says these
are government requirements, it is true. Pass this along to your mortgage lenders.
OCC releases 2014 schedule of workshop for directors
The OCCC announced its 2014 schedule of workshops for directors of national
community banks and federal savings associations. The OCC examiner-led workshops
provide practical training and guidance to directors of national community banks and
federal savings associations to support the health of community-based financial
institutions.
The OCC offers four workshops at a cost of $99 each:
CFPB blog34
Live from Phoenix!35 (CFPB Director’s remarks from and a recording of the Phoenix
mortgage event.)
If you’re having trouble paying your mortgage, here’s how you can take control36
Qualified Mortgages – What are they and what do they mean for you37
Helping student loan borrowers stay afloat38
Here’s what the new mortgage rules mean for you39
It’s back to basics for mortgage market in 201440
Save the date, Phoenix!41 Announcement of the January 10th event, “Protecting
homeowners: New tools for empowering consumers and advocates,” in Phoenix.
Sunshine for student financial products42
Join us in making mortgage shopping easier43
Explainer: What the multi-billion dollar Ocwen enforcement action means for you44
What we’ve been doing for youth financial capability45
Ally to repay $80 million to consumers it discriminated against46
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Publications, reports, studies, testimony & speeches
CRA/HMDA Reporter Newsletter
The January edition of the FFIEC’s CRA/HMDA Reporter Newsletter47 is available on
the FFIEC web site. The newsletter provides information on various topics to assist in
the collection and reporting of CRA and HMDA data. It informs readers of new
developments and changes for the upcoming processing year as well as answers to
commonly-asked questions.
Comment: The FFIEC also offers an archive48 of the newsletter going back to 1999.
CFPB releases Ability-to-Repay: Fact vs. Fiction Guide
The Ability-to-Repay and Qualified Mortgage rule went into effect on January 10, 2014.
There have been rumors about what the rule does and does not do. For that reason, the
CFPB released the Ability-to-Repay: Fact vs. Fiction Guide49.
Comment: You might have your non-mortgage lending staff review this to dispel any
myths they might have.
FDIC: Winter 2013 Supervisory Insights
The Winter 2013 issue of Supervisory Insights50 features articles addressing the
importance of effective interest-rate risk management, results of the FDIC's Credit and
Consumer Products/Services Survey, and the new Basel III definition of capital.
2013 Federal Reserve Payments Study
The 2013 Federal Reserve Payments Study is the fifth in a series of triennial studies
conducted since 2001 by the Federal Reserve System to estimate aggregate trends in
noncash payments in the United States.
Comment: The study states the obvious. Card based payments are increasing at a rate
exceeding the decline of check payments. Debit card payments have increased more than
any other payment type. Paper checks remain significant, but most of them are processed
and cleared electronically. One in six checks was deposited as an electronic image.
Unauthorized transactions in 2012 numbered 31.1 million, with a value of $6.1 billion.
Cards had higher unauthorized transactions by number and value. Among cards, PIN
debit card transactions had the lowest fraud rates by number and value. Among
signature and credit card payments in 2012, card-not-present fraud rates were 3 times as
high as card-present fraud.
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Federal Reserve Bulletin
Mortgage Market Conditions and Borrower Outcomes: Evidence from the 2012 HMDA
Data and Matched HMDA-Credit Record Data51 This article describes mortgage lending
activity in 2012 based on newly available data reported under the Home Mortgage
Disclosure Act of 1975 (HMDA). It also examines a new data set composed of HMDA
records matched to borrowers’ credit records. The matched data help document
differences in the financial circumstances (credit scores and debt-to-income ratios) and
subsequent loan performance of borrowers grouped by their race or ethnicity and
income.
Consumer Experiences with Credit Cards52 This article examines consumers' behavior,
experiences, and attitudes regarding credit cards in the aftermath of the Great Recession
and the implementation of the Credit Card Accountability Responsibility and Disclosure
Act of 2009.
Comment: This is one of the more interesting findings from the mortgage market article:
“Loans to low- and moderate-income borrowers made by banking institutions in 2006
within their CRA assessment areas--loans that the CRA encourages--had a delinquency
rate that was lower than that for all loans combined and less than one-fourth the rate for
all higher-priced loans of the same vintage. These findings are inconsistent with the
notion that the CRA was a principal driver of the mortgage and financial crisis.”
Of the 14 findings in the credit card article, numbers 13 and 14 were probably the most
interesting:
13. Most cardholders who hardly ever paid their monthly balance in full or who made
only the required minimum payments believed that credit cards made managing their
finances less difficult and were satisfied with their accounts. This belief does not seem to
support the hypothesis that consumers overestimate their ability to repay their credit
card debt.
14. New disclosures appear to have had little effect on the share of cardholders who make
only the required minimum payments.
Fed Community Affairs Letters
Revised RESPA Interagency Examination Procedures (CA 13-24)53 reflect recent
amendments to RESPA issued by the CFPB.
Revised Interagency Procedures for Regulation Z and Applicability of CA Letter 09-12
(CA 13-25)54
Regulation X Homeownership Counseling List Requirement (CA 13-26)55 provides two
alternatives for lenders to provide the counseling list: (1) obtain the list through a CFPBcreated website; or (2) generate the list themselves based on specific CFPB instructions.
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Fed updates its Consumer Compliance Handbook
The November 2013 update to the Consumer Compliance Handbook56 reflects updated
interagency examination procedures for Regulation E - Electronic Funds Transfer; Fair
Credit Reporting; Real Estate Settlement Procedures Act; and Regulation Z - Truth in
Lending. This transmittal also includes an executive summary of a newly adopted
Community Bank Risk-Focused Consumer Compliance Supervision Program. In
addition, a new section on Garnishment of Accounts Containing Federal Benefit
Payments is added.
FedFlash for January
The January updates57 include articles on new features of the FedTransaction® tool; ensuring
an institution has a current board resolution and an official authorization list on file; new webinar
for account management information and accounting information services data file changes;
change to e-payments routing directory; 2014 Federal Reserve Financial Services fees effective
January 2, 2014; new FedReceipt RTNs, changes to case submission requirements for PAIDs;
and change to e-payments routing directory.
Fed issues January FedFocus
FedFocus58 provides the latest Federal Reserve Financial Services news. Each edition
keeps you informed about hot topics in the industry, as well as provides insight into the
value of Federal Reserve Financial Services. The January edition of FedFocus includes
these topics: Payment Study, data automation, business continuity, America the
Beautiful quarters, and new/updated check adjustment webinars.
Agency rulemaking:
Selected final rules since last Capitol Comments:
Treatment of Certain Collateralized Debt Obligations Backed Primarily by
Trust Preferred Securities with Regard to Prohibitions and Restrictions on
Certain Interests in, and Relationships with, Hedge Funds and Private
Equity Funds59 The OCC, Board, FDIC, CFTC and SEC are each adopting a common
interim final rule that would permit banking entities to retain investments in certain
pooled investment vehicles that invested their offering proceeds primarily in certain
securities issued by community banking organizations of the type grandfathered under
section 171 of the Dodd - Frank Wall Street Reform and Consumer Protection Act
(“Dodd - Frank Act”) . The interim final rule is a companion rule to the final rules
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adopted by the Agencies to implement section 13 of the Bank Holding Company Act of
1956 (“BHC Act”) , which was added by section 619 of the Dodd-Frank Act .
Effective date: The interim final rule is effective on April 1, 2014. Comment date:
Comments on the interim final rule should be received on or before 30 days after
publication in the Federal Register, which hadn’t happened at time of Capitol Comment
publication.
Selected federal rule proposals with open comment
periods:
Proposed Interagency Policy Statement Establishing Joint Standards for
Assessing the Diversity Policies and Practices of Entities Regulated by the
Agencies and Request for Comment60 The OCC, Board, FDIC, NCUA, CFPB, and
SEC (each an “Agency” and collectively, the “Agencies”) are proposing joint standards
for assessing the diversity policies and practices of the entities they regulate. Section 342
of the Dodd-Frank Act directed the establishment of an Office of Minority and Women
Inclusion (“OMWI Office”) in each Agency. Each OMWI Office is headed by a Director
and is responsible for all Agency matters relating to diversity in management,
employment, and business activities. Section 342(b)(2)(C) directs each Agency's OMWI
Director to develop standards for assessing the diversity policies and practices of entities
regulated by that Agency. This proposed interagency policy statement (“Statement”)
identifies these proposed standards and requests comment on all aspects of this
Statement. To allow the public more time to consider the proposed assessment
standards, the Agencies determined61 that an extension of the comment period to
February 7, 2014, is appropriate. This action will allow interested persons additional
time to analyze the interagency policy statement and prepare their comments.
Comments must be received on or before February 7, 2014.
Treatment of Certain Collateralized Debt Obligations Backed Primarily by
Trust Preferred Securities with Regard to Prohibitions and Restrictions on
Certain Interests in, and Relationships with, Hedge Funds and Private
Equity Funds62 See final rule section, above, for description of this interim final rule.
Comment date: Comments on the interim final rule should be received on or before 30
days after publication in the Federal Register, which hadn’t happened at time of Capitol
Comment publication.
Debt Collection (Reg. F)63 The CFPB is seeking comment, data, and information
from the public about debt collection practices. Debt collection affects a significant
number of consumers and the Bureau is considering proposing rules relating to debt
collection. Therefore, the Bureau is interested in learning through responses to this
advance notice of proposed rulemaking (ANPR) about the debt collection system, about
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consumer experiences with the debt collection system, and about how rules for debt
collectors might protect consumers without imposing unnecessary burdens on industry.
Originally, the Debt Collection ANPR allowed a 90-day comment period, closing on
February 10, 2014. The CFPB extended the comment period to February 28, 2014.
Fed: Availability of Funds and Collection of Checks The Fed requested public
comment on proposed amendments to check collection and return rules to reflect the
evolution of the nation’s check collection system from one that is largely paper-based to
one that is virtually all electronic.
The check collection and return provisions in Regulation CC currently apply only to
paper checks. The Board is proposing that electronic checks and electronic returned
checks that banks exchange by agreement also be subject to these rules unless otherwise
agreed by the sending and receiving banks. In addition, the Board is requesting
comments on alternative approaches to modify the current expeditious-return and
notice of nonpayment requirements to encourage the few remaining banks demanding
paper returns to accept electronic returns.
The Board is also proposing a new indemnity for electronic items cleared through the
check-collection system that did not originate as paper checks. Comments must be
submitted by May 2, 2014.
Selected federal proposed rulemaking with closed
comment periods—final rule not yet issued:
FDIC: Restrictions on Sales of Assets of a Covered Financial Company by
the Federal Deposit Insurance Corporation64 The FDIC proposed a rule to
implement a section of the Dodd-Frank Act. Under the section, individuals or entities
that have, or may have, contributed to the failure of a “covered financial company”
cannot buy a covered financial company's assets from the FDIC. This proposed rule
establishes a self-certification process that is a prerequisite to the purchase of assets of a
covered financial company from the FDIC. Comments close on January 6, 2014.
Federal banking regulators propose rules on loans in areas having Special
Flood Hazards65 The OCC, FRB, FDIC, FCA, and NCUA (collectively, the Agencies)
are proposing to amend their regulations regarding loans in areas having special flood
hazards to implement provisions of the Biggert-Waters Flood Insurance Reform Act of
2012. Specifically, the proposal would establish requirements with respect to the escrow
of flood insurance payments, the acceptance of private flood insurance coverage, and the
force-placement of flood insurance. The proposal also would clarify the Agencies’ flood
insurance regulations with respect to other amendments made by the Act and make
technical corrections. Furthermore, the OCC and the FDIC are proposing to integrate
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their flood insurance regulations for national banks and Federal savings associations
and for State non-member banks and State savings associations, respectively.
Comments must be received by December 10, 2013. (The government shutdown has
affected the Office of Federal Register.) FIL-48-201366.
Comment: IBAT filed its comment letter in response to FDIC's proposed rules on loans in
areas having special flood hazards. The letter drew attention to IBAT member concerns
regarding:
1. The ability to determine if private flood insurance is at least as broad as policies
provided under standard National Flood Insurance Program policies;
2. Escrow requirements for all loans subject to mandatory purchase requirements
regardless of whether the loan closed before or after the rule’s effective date; and
3. A lack of clarity as to whether banks have the ability to recoup costs incurred in
obtaining force placed insurance in the event of borrower default.
Highlights of the proposal: The proposal would generally require regulated lending
institutions, or servicers acting on their behalf, to escrow premiums and fees for flood
insurance for any loans secured by residential improved real estate or a mobile home,
unless the institutions qualify for the statutory exception. The proposal would also
require that regulated lending institutions accept private flood insurance that meets the
statutory definition to satisfy the mandatory purchase requirement. The proposal
requests comment on whether the Agencies should accept policies that don’t meet the
FDPA definition of private flood insurance and what the Agencies might require for such
a policy. The proposal includes new and revised sample notice forms and clauses. One of
the new sample notice forms is Notice of Requirement to Escrow for Outstanding Loans to
inform borrowers of the new escrow requirement. The proposal would amend the forceplacement provisions to clarify that a lender or servicer has authority to charge for flood
insurance on the date coverage lapses or becomes insufficient.
Six agencies repropose risk retention rule67 This proposal was issued jointly by
the Fed, HUD, the FDIC, FHFA, the OCC, and the SEC. The rule would provide assetbacked securities (ABS) sponsors with several options to satisfy the risk retention
requirements. The original proposal generally measured compliance with the risk
retention requirements based on the par value of securities issued in a securitization
transaction and included a so-called premium capture provision. The agencies are now
proposing that risk retention generally be based on fair value measurements without a
premium capture provision. Comments were due on or before October 30, 2013.
CFPB: Proposes Consumer Financial Civil Penalty Fund68 Concurrent with
issuing a final rule, the CFPB also published a proposal and is seeking comments on
possible revisions, adjustments, and refinements to the final rule. The comment period
closed on July 8, 2013.
Comment: Click here69 to learn about the CFPB’s Civil Penalty Fund.
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Selected upcoming final federal rule
compliance dates:
04.01.2014
Treatment of Certain Collateralized Debt Obligations Backed Primarily by Trust Preferred
Securities with Regard to Prohibitions and Restrictions on Certain Interests in, and Relationships
with, Hedge Funds and Private Equity Funds70 The OCC, Board, FDIC, CFTC and SEC are each
adopting a common interim final rule that would permit banking entities to retain investments in
certain pooled investment vehicles that invested their offering proceeds primarily in certain
securities issued by community banking organizations of the type grandfathered under section 171
of the Dodd - Frank Wall Street Reform and Consumer Protection Act (“Dodd - Frank Act”) . The
interim final rule is a companion rule to the final rules adopted by the Agencies to implement
section 13 of the Bank Holding Company Act of 1956 (“BHC Act”) , which was added by section
619 of the Dodd-Frank Act .
04.01.2014
OCC, Fed, FDIC, and SEC: Prohibitions and Restrictions on Proprietary Trading and Certain
Interests in, and Relationships with, Hedge Funds and Private Equity Funds (the Volcker Rule) 71
The Agencies adopted a rule that would implement section 13 of the BHC Act, which was added by
section 619 of the Dodd-Frank Act.” Section 13 contains certain prohibitions and restrictions on the
ability of a banking entity and nonbank financial company supervised by the Board to engage in
proprietary trading and have certain interests in, or relationships with, a hedge fund or private
equity fund. Statement by Chairman Ben S. Bernanke.Statement by Governor Daniel K. Tarullo.
Final Rule - Preamble (7.2 MB PDF). Fact Sheet (PDF). Community Bank Guide (PDF).
08.15.2015
CFPB: Final integrated Mortgage Disclosures Under the RESPA (Reg. X) and the Truth In Lending
Act (Reg. Z)72 Notice of final rule and official interpretations. CFPB blog on the disclosure.
Comment: Distribute this calendar to your CEO, CFO, Compliance Officer, and Operations
Officer.
Selected final federal rule compliance dates from
the past 12 months:
Our list of past final rule effective dates is limited to 12 months. To see the document
“Selected Past Final Federal Rules,” containing future and past selected final rules, click
here.
01.18.2014
Federal Banking Regulators: Appraisals for Higher-Priced Mortgage Loans – Supplemental Final
73
Rule Alternative provisions regarding manufactured home loans are effective July 18, 2015, as
indicated in the Supplementary Information, regulation text and Official Staff Commentary.
01.18.2014
CFPB: Disclosure and Delivery Requirements for Copies of Appraisals and Other Written
Valuations Under ECOA/Regulation B74
o1.18.2014
CFPB, FRB, FDIC, FHFA, NCUA, and OCC: Appraisals for Higher-Priced Mortgage Loans75
01.13.2014
SEC: Registration of Municipal Advisors76 The SEC adopted new Rules 15Ba1-1 through 15Ba1-8,
new Rule 15Bc4-1, and new Forms MA, MA-I, MA-W, and MA-NR under the Exchange Act. These
rules and forms are designed to give effect to provisions of Title IX of the Dodd-Frank Act that,
among other things, require the Commission to establish a registration regime for municipal
advisors and impose certain record-keeping requirements on such advisors.
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01.10.2014
Homeownership Counseling Organizations Lists Interpretive Rule77 This rule describes data
instructions for lenders to use in complying with the requirement under the High-Cost Mortgage
and Homeownership Counseling Amendments to the Truth in Lending Act (Regulation Z) and
Homeownership Counseling Amendments to RESPA Final Rule to provide a homeownership
counseling list using data made available by the CFPB or HUD.
01.10.2014
HUD: Qualified Mortgage Definition for HUD Insured and Guaranteed Single Family Mortgages 78
Through this final rule, HUD establishes a definition of “qualified mortgage” for the single family
residential loans that HUD insures, guarantees, or administers that aligns with the statutory
ability-to-repay criteria of the TILA and the regulatory criteria of the definition of “qualified
mortgage” promulgated by the CFPB).
01.10.2014
CFPB: Amendments to the 2013 Mortgage Rules under the RESPA (Regulation X) and the TILA
(Regulation Z) This rule amends provisions in Regulation Z and final rules issued by the CFPB in
2013, which, among other things, required that consumers receive counseling before obtaining
high-cost mortgages and that servicers provide periodic account statement s and rate adjustment
notices to mortgage borrowers, as well as engage in early intervention when borrowers become
delinquent. The amendments clarify the specific disclosures that must be provided before
counseling for high-cost mortgages can occur, and proper compliance regarding servicing
requirements when a consumer is in bankruptcy or sends a cease communication request under the
Fair Debt Collection Practices Act. The rule also makes technical corrections to provisions of other
rules. The Bureau requests public comment on these changes.
01.10.2014
CFPB: Loan Originator Compensation Requirements Under TILA/Regulation Z 79 Amendments to
§1026.36(h) and (i), which are a prohibition on financing credit insurance in connection with
consumer credit transactions secured by a dwelling, and which were to be effective on June 1, 2013,
will now be effective on January 10, 2014 after clarifications are adopted. Click here80 to read the
notice of the delay of the effective date.
01.10.2014
CFPB: RESPA/Regulation X and TILA/Regulation Z Mortgage Servicing81 RESPA final rule
includes servicer’s’ obligations to correct errors asserted by mortgage loan borrowers; provide
certain information requested by such borrowers; and provide protection to such borrowers in
connection with force-placed insurance. The Reg. Z final rule includes initial rate adjustment
notices, periodic statements for residential mortgage loans, crediting of mortgage payments; and
responses to requests for payoff amounts. This final rule was further corrected, clarified, and
amended: CFPB finalizes corrections, clarifications, and amendments to mortgage rules82:
●Clarifies how to determine a consumer’s debt-to-income (DTI) ratio: ●Explains that CFPB’s
RESPA rule does not preempt the field of servicing regulation by states. ●Establishes which
mortgage loans to consider in determining small servicer status. ●Clarifies the eligibility standard
of the temporary QM provision.
01.10.2014
CFPB: Clarifications to the 2013 Mortgage Rules under the Equal Credit Opportunity Act
(Regulation B), Real Estate Settlement Procedures Act (Regulation X), and the Truth in Lending
Act (Regulation Z) Among other things, these amendments: ●Clarify what servicer activities are
prohibited in the first 120 days of delinquency; ●Facilitate servicers’ offering of short-term
forbearance plans; ●Clarify best practices for informing borrowers about the address for error
resolution documents; ●Facilitate lending in rural and underserved areas, while the CFPB is
reexamining the rural and underserved definitions, by: 1) Exempting all small creditors from a new
ban on high-cost mortgages featuring balloon payments so long as certain restrictions are met; and
2) making it easier for certain small creditors to continue to qualify for an exemption from a
requirement to maintain escrows on certain HPMLs; ●Make clarifications about financing of credit
insurance premiums; ●Clarify the definition of a loan originator; ●Clarify the points and fees
thresholds and loan originator compensation rules for manufactured housing employees; ●Revise
effective dates of many loan originator compensation rule provisions.
01.10.2014
CFPB: Ability to Repay (ATR) and Qualified Mortgage (QM) Standards under TILA/Regulation Z 83
01.10.2014
CFPB: High-Cost Mortgage and Homeownership Counseling Amendments to TILA/Regulation Z
and Homeownership Counseling Amendments to RESPA/Regulation X84 implements Dodd-Frank
Act amendments to TILA and RESPA. Expands the types of mortgage loans subject to the
protections of HOEPA, revises and expands the tests for coverage under HOEPA, and imposes
CAPITOL
COMMENTS
JANUARY 2014
Page 16
additional restrictions on mortgages that are covered by HOEPA, including a pre-loan counseling
requirement.
01.03.2014
FinCEN and Fed: Definitions of Transmittal of Funds and Funds Transfer85 FinCEN and the Fed
are issuing this Final Rule amending the regulatory definitions of ‘‘funds transfer’’ and ‘‘transmittal
of funds’’ under the regulations implementing the BSA. We are amending the definitions to
maintain their current scope in light of changes to the EFTA, which will avoid certain currently
covered transactions being excluded from BSA requirements.
01.01.2014
FDIC: Interim rule revising risk-based and leverage capital requirements86 The FDIC adopted an
interim final rule that revises its risk-based and leverage capital requirements for FDIC-supervised
institutions. This interim final rule is substantially identical to a joint final rule issued by the OCC
and the Federal Reserve (together, with the FDIC, the agencies).
01.01.2014
Fed: Regulatory Capital Rules (Basel III)87 The Fed approved a Basel III final rule. The final rule
minimizes burden on smaller, less complex financial institutions. For more details, refer to the
Federal Reserve’s Press Release88. The FDIC Board of Directors approved an interim final rule89
that adopts with revisions the three notices of proposed rulemaking (NPRs) that the banking
agencies proposed last year related to Basel III and the standardized approach. The FDIC Board
also approved a joint interagency Notice of Proposed Rulemaking90 to strengthen the
supplementary leverage requirements for the largest most systemically important banking
organizations. The OCC announced (NR 2013-11091) that it approved a final rule revising regulatory
capital rules applicable to national banks and federal savings associations.
11.04.2013
Final rule prohibiting issuing credit card unless ability to make payments is considered (Reg. Z)
10.28.2013
CFPB: Final Consumer protection rule on international remittances (Reg. E) This rule was followed
by a clarification: CFPB Final Rule: Clarificatory amendment and technical correction to a final rule
and official interpretation of disclosures for remittance transactions (Reg. E)
10.17.2013
FHA approval of lending institutions and mortgagees: streamlined reporting requirements for
small supervised lenders and mortgagees92 This rule streamlines the FHA financial statement
reporting requirements for lenders and mortgagees who are supervised by federal banking agencies
and whose consolidated assets do not meet the thresholds set by their supervising federal banking
agencies for submission of audited financial statements (currently set at $500 million in
consolidated assets).
09.26.2013
CFPB: Rules of Practice for Issuance of Temporary Cease-and-Desist Orders The Dodd-Frank Act
requires the CFPB to prescribe rules establishing procedures for the conduct of adjudication
proceedings. On June 29, 2012, the Bureau published the final Rules of Practice for Adjudication
Proceedings. That final rule, however, does not apply to the issuance of a temporary cease-anddesist order (TCDO) pursuant to section 1053(c) of the Dodd-Frank Act. The CFPB issued an
interim final rule governing such issuance and seeks public comments. The interim final rule took
effect on September 26, 2013.
07.01.2013
FTC: Amends the Children's Online Privacy Protection Rule (“COPPA Rule” or “Rule”), consistent
with the requirements of the Children's Online Privacy Protection Act, to clarify the scope of the
Rule and strengthen its protections for children's personal information, in light of changes in online
technology since the Rule went into effect in April 2000. The final amended Rule includes
modifications to the definitions of operator, personal information, and Web site or online service
directed to children. The amended Rule also updates the requirements set forth in the notice,
parental consent, confidentiality and security, and safe harbor provisions, and adds a new provision
addressing data retention and deletion. (Comment: Financial institutions are subject to COPPA if
they operate a website or online services directed to children or have actual knowledge that they are
collecting or maintaining personal information from a child online.)
06.01.2013
CFPB: Escrow Requirements for Higher-Priced Mortgages Under TILA/Regulation Z 93 The CFPB
issued Clarifications of the 2013 Escrows final rule94 (Reg. Z) on May 16, 2013.
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Page 17
06.01.2013
Amendments in the Loan Originator Compensation final rules95 to §1026.36 (h) and (i) are effective
on this June 1, 2013. Section 1026.36(h) is regarding the prohibition on mandatory arbitration
clauses and waivers of certain consumer rights. Section 1026(i) is regarding the prohibition on
financing single-premium credit insurance.
03.31.2013
FinCEN: SAR/CTR batch filers must update their systems to the new specifications96. (Extended
from June 30, 2012 to March 31, 201397) All institutions that batch file the current CTR, CTR-C,
SAR-DI, SAR-SF, SAR-MSB, or SAR-C will have to convert their systems to file the new CTR and
SAR. FinCEN will make other filing technical specifications available in the near future.
03.28.2013
In order to resolve litigation regarding a Reg. Z provision limiting fees a consumer must pay prior
to opening a credit card account, the CFPB issued an April 2012 proposal to amend the rule to be
consistent with a court ruling so that it no longer applies to fees charged prior to account opening.
On March 22, the CFPB adopted a final rule98 adopting the proposal’s elimination of the cap on fees
charged prior to account opening.
03.26.2013
The CFPB amended Reg. E99 to conform to legislation that amended the EFTA to eliminate a
requirement that owners of ATMs post a fee notice on all ATMs. The onscreen notice requirement
remains.
01.01.2013
The IRS final regulations100 regarding the reporting requirements for interest that relates to
deposits maintained at U.S. offices of certain financial institutions and is paid to certain
nonresident alien individuals. These regulations apply to payments of interest made on or after
January 1, 2013.
12.31.2012
Housing and Economic Recovery Act by The Helping Heroes Keep Their Homes Act of 2010 – The
provision for an extended time period (extended from 90 days to nine months) for protections
affecting foreclosure, sale, or seizure of servicemembers’ real or personal property expires.
IBAT educational opportunities:
Jan 22, 2014
Jan 23, 2014
Webinar
Webinar
Jan 28, 2014 to Jan 30,
2014
Jan 28, 2014
Lubbock, TX
Jan 29, 2014
Jan 29, 2014
Jan 30, 2014
Jan 30, 2014
Feb 4, 2014
Feb 7, 2014
Feb 9, 2014 to Feb 14,
2014
Feb 9, 2014 to Feb 11,
2014
Feb 11, 2014 toFeb 13,
2014
Feb 12, 2014
Feb 13, 2014
Feb 15, 2014
Feb 20, 2014 to Feb 21,
2014
Feb 21, 2014
Houston, TX
Webinar
Houston, TX
Webinar
Houston, TX
Conference Call
Dallas, TX
CAPITOL
Webinar
Commercial Appraisal Review: Income Versus Sales Comparison Approach
What is That Personal Tax Return Telling Me? Part 1: Form 1040, Schedules B,
C&D
2014 Real Estate Lending Compliance - Lubbock
Required Compliance Series: Required Compliance for the Board & Senior
Management, Including BSA
2014 Mortgage Lending: Start to Finish - Houston
CFPB Examination Procedures for International Remittance Transfers
2014 Mastering HMDA - Houston
Your Assets Have Gone Mobile – Have Your Security Plans Kept Up?
2014 Anti-Money Laundering and Bank Secrecy Act - Houston
Associate Member Industry Update Conference Call
2014 ICBA Compliance Institute
South Lake Tahoe,
NV
Irving, TX
Winter Summit XIV
Lubbock, TX
Lubbock, TX
Edinburg, TX
Dallas, TX
2014 Mortgage Lending: Start to Finish - Lubbock
2014 Mastering HMDA - Lubbock
Teach the Teacher Program - Edinburg
Hold, Fold or Raise? An M&A Workshop for Community Banks
Webinar
Dissecting the New CFPB Mortgage Rule Exam Procedures for TILA & RESPA
2014 Real Estate Lending Compliance - Irving
COMMENTS
JANUARY 2014
Page 18
Feb 26, 2014 to Feb 28,
2014
Mar 12, 2014
Mar 13, 2014
Mar 18, 2014
Mar 18, 2014 to Mar 20,
2014
Mar 19, 2014 to Mar 20,
2014
Mar 26, 2014 to Mar 27,
2014
Apr 17, 2014 to Apr 18,
2014
Apr 29, 2014 to Apr 30,
2014
Aug 14, 2014 to Aug 15,
2014
Aug 28, 2014
Nov 6, 2014
Maui, Hawaii
IBAT's Pre-ICBA Convention Program
Tyler, TX
Tyler, TX
Dallas, TX
Houston, TX
2014 Mortgage Lending: Start to Finish - Tyler
2014 Mastering HMDA - Tyler
2014 Credit Analysis Summit
2014 Real Estate Lending Compliance - Houston
Dallas, TX
2014 Advanced Credit Analysis Summit
San Antonio, TX
How to Create and Maintain a Sales Culture in a Community Bank
San Antonio, TX
2014 Lending Compliance Summit
San Antonio, TX
2014 Nuts and Bolts of Banking Summit
Dallas, TX
2014 Operations Compliance Summit
San Antonio, TX
San Antonio, TX
2014 Appraisals Summit
2014 Investment & Asset/Liability Management Summit
Common words, phrases, and acronyms
APOR
“Average Prime Offer Rates”
are derived from average
interest rates, points, and
other pricing terms offered
by a representative sample of
creditors for mortgage
transactions that have lowrisk pricing characteristics.
ATM
Automated Teller Machine
CARD Act
Credit Card Accountability
Responsibility and
Disclosure Act of 2009
CFPB
Consumer Financial
Protection Bureau
CFR
Code of Federal Regulations.
Codification of rules and
regulations of federal
agencies.
CRA
Community Reinvestment
Act. This Act is designed to
encourage loans in all
segments of communities.
CRE
Commercial Real Estate
CSBS
Conference of State Bank
Supervisors
CAPITOL
COMMENTS
JANUARY 2014
Page 19
CTR
Currency Transaction
Report. Filed for each
deposit, withdrawal,
exchange of currency that
involves a transaction in
currency of more than
$10,000.
Dodd-Frank Act
The Dodd–Frank Wall Street
Reform and Consumer
Protection Act
FDIC
Federal Deposit Insurance
Corporation
EFTA
Electronic Fund Transfer Act
Federal bank regulatory
agencies
FDIC, FRB, and OCC
Federal financial
institution regulatory
agencies
CFPB, FDIC, FRB, NCUA,
and OCC
FEMA
Federal Emergency
Management Agency
FFIEC
Federal Financial
Institutions Examination
Council
FHFA
Federal Housing Finance
Agency
FHA
Federal Housing
Administration
FinCEN
Financial Crime
Enforcement Network
FR
Federal Register. U.S.
government daily
publication that contains
proposed and final
administrative regulations of
federal agencies.
FRB (or Fed)
Federal Reserve Board
FSOC
Financial Stability Oversight
Council
FTC
Federal Trade Commission
GAO
Government Accountability
Office
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COMMENTS
JANUARY 2014
Page 20
HARP
Home Affordable Refinance
Program
HAMP
Home Affordable
Modification Program
HMDA
Home Mortgage Disclosure
Act
HOEPA
Home Ownership and Equity
Protections Act of 1994
HPML
Higher Priced Mortgage
Loan
HUD
U.S. Department of Housing
and Urban Development
IRS
Internal Revenue Service
MLO
Mortgage Loan Originator
MOU
Memorandum of
Understanding
NFIP
National Flood Insurance
Program. U.S. government
program to allow the
purchase of flood insurance
from the government.
NMLS
National Mortgage Licensing
System
OCC
Office of the Comptroller of
the Currency
OFAC
Office of Foreign Asset
Control
OREO
Other Real Estate Owned
QRM
Qualified Residential
Mortgage
Reg.
Abbreviation for
“Regulation” – A federal
regulation. These are found
in the CFR.
Reg. B
Equal Credit Opportunity
Reg. C
Home Mortgage Disclosure
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COMMENTS
JANUARY 2014
Page 21
Reg. DD
Truth in Savings
Reg. E
Electronic Fund Transfers
Reg. G
S.A.F.E. Mortgage Licensing
Act
Reg. P
Privacy of Consumer
Financial Information
Reg. X
Real Estate Settlement
Procedures Act
Reg. Z
Truth in Lending
RESPA
Real Estate Settlement
Procedures Act
SAR
Suspicious Activity Report –
Report financial institutions
file with the U.S.
government (FinCEN)
regarding activity that may
be criminal in nature.
SDN
Specially Designated
National
TILA
Truth in Lending Act
TIN
Tax Identification Number
Treasury
U.S. Department of Treasury
This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is
provided with the understanding that the publisher is not engaged in the rendering of legal, accounting or other professional
advice - from a Declaration of Principles adopted by the American Bar Association and a Committee of Publishers and
Associations; All rights reserved; Shannon Phillips Jr., Editor; Oklahoma Edition, copyrighted by Craig Buford, CBAO
President and CEO.
Capitol Comments
January 2014
Craig Buford, CAE
President and CEO
Community Bankers Association of Oklahoma
4101 Perimeter Center Drive, Suite 107
Oklahoma City, OK 73112
Office: 405-524-4122
Cell: 405-833-9499
Fax: 405-601-1605
cbuford@cba-ok.org
www.cba-ok.org
CAPITOL
COMMENTS
JANUARY 2014
Page 22
1
http://www.occ.gov/news-issuances/news-releases/2014/nr-ia-2014-2a.pdf
2
https://www.federalregister.gov/articles/2014/01/15/2014-00635/consumer-advisory-board-and-councilssolicitation-of-applications-for-membership
3
4
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20131219c1.pdf
http://www.ffiec.gov/cra/
5
http://www.consumerfinance.gov/newsroom/cfpb-and-doj-order-ally-to-pay-80-million-to-consumers-harmed-bydiscriminatory-auto-loan-pricing/
6
https://www.federalregister.gov/articles/2013/12/26/2013-30723/bank-secrecy-act-advisory-group-solicitation-ofapplication-for-membership
7
8
9
http://www.occ.gov/news-issuances/bulletins/2013/bulletin-2013-40.html
http://www.occ.gov/news-issuances/federal-register/78fr70624.pdf
http://www.federalreserve.gov/bankinforeg/caletters/CA13-07attachment.pdf
10
http://files.consumerfinance.gov/f/201304_cfpb_payday-dap-whitepaper.pdf
11
https://www.federalregister.gov/articles/2013/12/30/2013-31223/home-mortgage-disclosure-regulation-cadjustment-to-asset-size-exemption-threshold
12
https://www.federalregister.gov/articles/2013/12/30/2013-31225/truth-in-lending-regulation-z-adjustment-to-assetsize-exemption-threshold
13
http://www.fdic.gov/news/news/press/2013/pr13127.html
14
http://www.fdic.gov/regulations/resources/director/technical/municipal.html
15
http://www.fdic.gov/regulations/resources/director/technical/alll.html
16
http://www.fdic.gov/regulations/resources/director/technical/tdr.html
17
http://www.fdic.gov/regulations/resources/director/technical/fair-lending.html
18
http://www.fdic.gov/regulations/resources/director/video.html
19
https://www.federalregister.gov/articles/2014/01/03/2013-31436/request-for-information-regarding-the-mortgageclosing-process
20
http://www.consumerfinance.gov/guidance/supervision/manual
21
http://www.fdic.gov/news/news/financial/2014/fil14001a.pdf
22
http://www.fdic.gov/news/news/financial/2014/fil14001.html
23
http://files.consumerfinance.gov/f/201401_cfpb_mortgage_request-error-resolution.pdf
24
http://files.consumerfinance.gov/f/201401_cfpb_mortgage_request-information-servicer.pdf
25
http://www.consumerfinance.gov/f/201312_cfpb_mortgages_help-for-struggling-borrowers.pdf
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Page 23
26
http://www.consumerfinance.gov/f/201312_cfpb_tipsforhomebuyers.pdf
27
http://www.consumerfinance.gov/f/201312_cfpb_mortgage-checklist.pdf
28
http://www.consumerfinance.gov/f/201312_cfpb_foreclosure-avoidance-checklist.pdf
29
http://www.consumerfinance.gov/askcfpb/search?sort=updated_at&selected_facets=category_exact%3Amortgages
30
http://www.consumerfinance.gov/find-a-housing-counselor/
31
http://www.consumerfinance.gov/complaint/
32
http://www.consumerfinance.gov/f/201312_cfpb_mortgagerules.pdf
33
http://www.consumerfinance.gov/f/201312_cfpb_foreclosure-avoidance-procedures.pdf
34
http://www.consumerfinance.gov/blog/
35
http://www.consumerfinance.gov/blog/live-from-phoenix/
36
http://www.consumerfinance.gov/blog/if-youre-having-trouble-paying-your-mortgage-heres-how-you-can-takecontrol/
37
http://www.consumerfinance.gov/blog/qualified-mortgages-what-are-they-and-what-do-they-mean-for-you/
38
http://www.consumerfinance.gov/blog/helping-student-loan-borrowers-stay-afloat/
39
http://www.consumerfinance.gov/blog/heres-what-the-new-mortgage-rules-mean-for-you/
40
http://www.consumerfinance.gov/blog/its-back-to-basics-for-the-mortgage-market-in-2014/
41
http://www.consumerfinance.gov/blog/save-the-date-phoenix/
42
http://www.consumerfinance.gov/blog/sunshine-for-student-financial-products/
43
http://www.consumerfinance.gov/blog/join-us-in-making-mortgage-shopping-easier/
44
http://www.consumerfinance.gov/blog/explainer-what-the-multi-billion-dollar-ocwen-enforcement-action-meansfor-you/
45
http://www.consumerfinance.gov/blog/what-weve-been-doing-for-youth-financial-capability/
46
http://www.consumerfinance.gov/blog/ally-to-repay-80-million-to-consumers-it-discriminated-against/
47
http://www.ffiec.gov/hmda/pdf/14news.pdf
48
http://www.ffiec.gov/hmda/newsletterArchive.htm
49
http://www.consumerfinance.gov/f/201312_cfpb_mortgage-rules_fact-vs-fiction.pdf
50
http://www.fdic.gov/regulations/examinations/supervisory/insights/index.html
51
http://www.federalreserve.gov/pubs/bulletin/2013/articles/hmda/default.htm
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Page 24
52
http://www.federalreserve.gov/pubs/bulletin/2013/pdf/consumer-experiences-with-credit-cards-201312.pdf
53
http://www.federalreserve.gov/bankinforeg/caletters/caltr1324.htm
54
http://www.federalreserve.gov/bankinforeg/caletters/caltr1325.htm
55
http://www.federalreserve.gov/bankinforeg/caletters/caltr1326.htm
56
http://www.federalreserve.gov/boarddocs/supmanual/default.htm#consumer
57
http://www.frbservices.org/fedflash/index.html
58
http://www.frbservices.org/fedfocus/index.html
59
http://www.occ.gov/news-issuances/news-releases/2014/nr-ia-2014-2a.pdf
60
http://www.gpo.gov/fdsys/pkg/FR-2013-10-25/html/2013-25142.htm
61
62
63
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20131219b1.pdf
http://www.occ.gov/news-issuances/news-releases/2014/nr-ia-2014-2a.pdf
https://www.federalregister.gov/articles/2013/11/12/2013-26875/debt-collection-regulation-f
64
https://www.federalregister.gov/articles/2013/11/06/2013-26544/restrictions-on-sales-of-assets-of-a-covered-financial-company-by-the-federaldeposit-insurance
65
http://www.fdic.gov/news/board/2013/2013-10-08_notice_dis_a_fr.pdf
66
http://www.fdic.gov/news/news/financial/2013/fil13048.html
67
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20130828a1.pdf
68
https://www.federalregister.gov/articles/2013/05/07/2013-10318/consumer-financial-civil-penalty-fund
69
http://www.consumerfinance.gov/budget/civil-penalty-fund/
70
71
http://www.occ.gov/news-issuances/news-releases/2014/nr-ia-2014-2a.pdf
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20131210a1.pdf
72
https://www.federalregister.gov/articles/2013/12/31/2013-28210/integrated-mortgage-disclosures-under-the-realestate-settlement-procedures-act-regulation-x-and-the
73
https://www.federalregister.gov/articles/2013/12/26/2013-30108/appraisals-for-higher-priced-mortgage-loans
74
http://www.consumerfinance.gov/regulations/disclosure-and-delivery-requirements-for-copies-of-appraisals-and-other-written-valuationsunder-the-equal-credit-opportunity-act-regulation-b/
75
http://www.consumerfinance.gov/regulations/appraisals-for-higher-priced-mortgage-loans/
76
77
https://www.sec.gov/rules/final/2013/34-70462.pdf
https://www.federalregister.gov/articles/2013/11/14/2013-27300/homeownership-counseling-organizations-lists-interpretive-rule
78
https://www.federalregister.gov/articles/2013/12/11/2013-29482/qualified-mortgage-definition-for-hud-insuredand-guaranteed-single-family-mortgages
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80
http://www.consumerfinance.gov/regulations/loan-originator-compensation-requirements-under-the-truth-in-lending-act-regulation-z/
http://files.consumerfinance.gov/f/201305_cfpb_final-rule_credit-insurance-effective-date-delay-final-rule-for-ofr-submission.pdf
81
http://www.consumerfinance.gov/regulations/2013-real-estate-settlement-procedures-act-regulation-x-and-truth-in-lending-act-regulation-zmortgage-servicing-final-rules/
82
https://www.federalregister.gov/articles/2013/07/24/2013-16962/amendments-to-the-2013-mortgage-rules-under-the-real-estate-settlementprocedures-act-regulation-x
83
http://www.consumerfinance.gov/regulations/ability-to-repay-and-qualified-mortgage-standards-under-the-truth-in-lending-act-regulation-z/
84
http://files.consumerfinance.gov/f/201301_cfpb_final-rule_high-cost-mortgages.pdf
85
http://www.gpo.gov/fdsys/pkg/FR-2013-12-04/pdf/2013-28951.pdf
86
https://www.federalregister.gov/articles/2013/09/10/2013-20536/regulatory-capital-rules-regulatory-capital-implementation-of-basel-iii-capitaladequacy-transition
87
https://www.federalregister.gov/articles/2013/10/11/2013-21653/regulatory-capital-rules-regulatory-capital-implementation-of-basel-iii-capitaladequacy-transition
88
http://www.federalreserve.gov/newsevents/press/bcreg/20130702a.htm
89
http://www.fdic.gov/news/board/2013/2013-07-09_notice_dis_a_res.pdf
90
http://www.fdic.gov/news/board/2013/2013-07-09_notice_dis_b_res.pdf
91
http://www.occ.gov/news-issuances/news-releases/2013/nr-occ-2013-110.html
92
https://www.federalregister.gov/articles/2013/09/17/2013-22583/federal-housing-administration-fha-approval-of-lending-institutions-andmortgagees-streamlined
93
http://files.consumerfinance.gov/f/201301_cfpb_final-rule_escrow-requirements.pdf
94
http://files.consumerfinance.gov/f/201305_cfpb_Escrows-Clarifications-final-rule.pdf
95
http://www.consumerfinance.gov/regulations/loan-originator-compensation-requirements-under-the-truth-in-lending-act-regulation-z/
96
http://www.fincen.gov/news_room/nr/html/20110902.html
97
http://www.fincen.gov/whatsnew/pdf/20111220.pdf
98
https://www.federalregister.gov/articles/2013/03/28/2013-07066/truth-in-lending-regulation-z
99
https://www.federalregister.gov/articles/2013/03/26/2013-06861/disclosures-at-automated-teller-machines-regulation-e
100
http://www.gpo.gov/fdsys/pkg/FR-2012-04-19/pdf/2012-9520.pdf
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